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December 7, 2015

To: The Honorable Mark Dayton, Governor of the State of Minnesota


From:
Edward P. Ehlinger, M.D., M.S.P.H
Commissioner
Minnesota Department of Health
John Linc Stine
Commissioner
Minnesota Pollution Control Agency
Tom Landwehr
Commissioner
Department of Natural Resources
Subject: Health Impact Assessment for Polymets copper-nickel mining project.
We are writing to explain the basis of the decision, which the three of us support, not to conduct
a separate Health Impact Assessment (HIA) for PolyMets proposed copper-nickel mining
project.
As you know, the Co-lead Agencies (MDNR, USFS, and USACE) recently published the Final
Environmental Impact Statement (FEIS) for this project. Prior to that, a Supplemental Draft EIS
(SDEIS) was published in December 2013 with a 90-day public comment period and three public
meetings. The MDH provided comments on the SDEIS that included both specific technical
comments related to the document and a suggestion that an HIA be considered for the project.
MDH is fully satisfied that the specific technical concerns raised with the SDEIS were addressed
in the FEIS. MDH is also convinced that an HIA would not provide any additional scientific
information regarding public health impacts and risks.
Human health information is summarized in section 7.3.4 of the FEIS, and is organized and
presented in a manner that is easily understandable by members of the public. This section also
directs readers to other sections of the FEIS where human health risks are examined and
mitigations are explained in very specific detail. The information in section 7.3.4 covers
concerns regarding potential health impacts from:
1. Exposure to air contaminants, particularly airborne amphibole mineral fibers;
2. Exposure to contaminants in drinking water, surface water, and food sources (e.g., wild
rice, and fish);

Governor Mark Dayton


December 7, 2015
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3. Increased risk of traffic accidents involving chemicals;


4. Increased exposure to noise and vibration; and
5. Strain on emergency response services.
These are among the general concerns that led MDH to suggest that an HIA be considered.
However, the three of us are confident that these concerns are properly addressed in the FEIS
and MDH no longer believes an HIA is necessary.
We have received additional requests from members of the public, including a group of Duluth
area physicians, for an HIA. We have considered the information provided as the basis for these
requests and have concluded that the FEIS adequately addressed public health impacts based on
water and air quality evaluation criteria and regulatory standards that are protective of human
health. Public health impacts were addressed in sections of the EIS related to water quality, air
quality and toxics, including potential effects to drinking water and food sources as required by
the Minnesota Environmental Policy Act and National Environmental Protection Act. Further,
as stated above, the FEIS includes a new section that concisely summarizes human health related
information and impact assessments within the document (section 7.3.4). Thus, it is still our
strong opinion that an HIA will not significantly inform the decisions regarding permits required
for the project beyond the information already available in the FEIS.
Furthermore, we do not believe it is practically or procedurally possible to pursue an HIA outside
of the EIS or permitting process at this point. An HIA would have the potential to introduce
unintended delay in decision making, legal risks, and public confusion about the linkage between
the HIA and FEIS processes and applicable laws. In particular, we are concerned that deciding
to conduct an HIA would call into question the completeness and adequacy of the FEIS and
could lead a court to order another supplemental draft EIS.
Our three agencies are deeply committed to protecting human health and the environment. We
also strongly believe that it is important to pursue a health in all policies approach to create and
maintain healthy Minnesota communities. Thus, as state agencies charged with making
important decisions about the future of our state, we are committed to carefully evaluating
PolyMets proposed NorthMet Project before making any permitting decisions.